The Effects of Meaningful Use Stage 3

Rumors about the next phase of the Centers for Medicare and Medicaid Services (CMS) EHR Incentive Program has prompted concern among healthcare providers. To truly understand meaningful use Stage 3 and its impact, it is important to differentiate between the rumors and the truth.

The final rule for meaningful use Stage 3 has yet to be published, so discussion on its effects are based on available drafts. Even those drafts are in question since the December 2013 announcement that Stage 3 would be delayed until 2017. One reason cited was to allow more time to research the impacts of Stage 2 before finalizing Stage 3. The delay will be particularly important for that research, since compared to Stage 1, 2011 Edition, there are so few Stage 2 vendors certified currently.

As for what is expected, the attention turns from data capture and access (Stage 1) and information exchange (Stage 2) to improved outcomes in Stage 3. One expected goal is to simplify and reduce the reporting requirements on those attesting. Some of that change can be achieved by consolidating the program’s current objectives, which I expect hospitals and providers will welcome, provided it truly reduces the reporting burden and does not coincide with other, new objectives and reporting requirements.

Stage 3’s goal of improving outcomes will be incredibly interesting – through November 2013, CMS had disbursed nearly $18 billion in incentive payments. Until now, the program’s success has been judged by the number of participants adopting certified EHRs. At some point during Stage 3 (or thereafter), we will know whether those payments have truly improved outcomes.

As Stage 2 has increased the requirements for providers to exchange records, Stage 3 will push those connections even further. It is expected that more interfaces will be needed for connecting to other systems, including other EHRs, registries, ACOs, and eventually entities like the Food and Drug Administration and Centers for Disease Control. Those interfaces usually cost providers money, so depending on the practice’s perspective on actual business need for more interfaces, healthcare providers will face even tougher decisions of whether to remain with Meaningful Use.

One proposed change for Stage 3 is to allow patients to submit their own health information. I believe this will really push EHR vendors more to shift their focus entirely onto other products and technologies, or partner with vendors who already have portal and patient engagement technologies. As these technologies advance and evolve, there may be new costs and fees associated with them.

Beyond the simple economics of new fees for interfaces, expanded patient portal functionality and so on, increased expectations related to patient engagement means that providers and clinics will spend more time electronically interacting with patients and their data. The time required to manage this patient engagement – and manage it well – will be important, since already in Stage 2, providers are measured on messages sent by their patients. As meaningful use continues to cause new expenses for providers to obtain these technologies and more time to manage them, we will see more providers spending time weighing the costs and benefits.

Vendors recognize the pros and cons of meaningful use. One big decision for them is weighing the need to become a certified product so that their clients can participate in meaningful use. Not all clients may be interested in the program. As such, a decision to pursue certification will almost certainly come at the expense of some clients who choose not to participate in meaningful use, as the vendor’s resources will likely be tied up creating features the latter clients do not need nor want.

Even if the decision to certify your product is easy, not every requirement of the program necessarily make sense for each provider. The “one size fits all” approach makes no sense in some segments of medicine – as many specialists could attest.

However, there are some good components to the program. Implementing standards and encouraging the exchange of records are two very important – and until now, largely unrealized – aspects of EHRs, and meaningful use is certainly helping to move those initiatives forward.

Stage 3 as currently proposed looks to be similar to what vendors experienced with the move to Stage 2 and 2014 Edition – more implementation of standards, and more opportunity for exchange of records. I think most vendors agree it is a positive that the program will continue the implementation of standards and support interoperability. But I also believe that vendors have doubts about the program’s claims of simplifying and streamlining the reporting functions.

As the terms of Stage 3 probably will change as officials analyze data on the effects of Stage 2, the best approach healthcare providers can take is assess internally what is working with Stage 2, make needed adjustments, and keep an eye out for updates as they occur.